Dark-pattern self-audits: turn two storefront observations into evidence
Work through a resetting countdown and a cart add-on, document context and remediation, and prepare for the annual self-audit and certificate requirement.
Read the guideCOMPLYCAT / DARK PATTERN AUDIT
A better experience.
A documented review.
Review storefront journeys for potential dark patterns, keep evidence, and prepare a human-reviewed yearly self-audit.
STOREFRONT REVIEW · EVIDENCE & ACTION
Dark Pattern AuditSAMPLE FINDING
From observation
to action.
to action.
Review what was observed, understand the context, then decide what needs to change.
Potential false urgencyNeeds review
A countdown restarts after a fresh visit. Check whether the offer actually ends when the timer reaches zero.
✓Observation capturedScreenshot
✓Mapped to guidanceFalse urgency
!Merchant reviewPending
Review workflowEvidence before a conclusion
A FOCUSED WORKFLOW
One job, thoughtfully covered.
Keep the essential steps together, from the first record to the next action.
Find what needs a closer look
Guided checks and automated observations where reliable, mapped to relevant dark-pattern categories.
Give findings their context
Keep screenshots, review decisions and recommended fixes together. Software flags; people decide where context matters.
Keep the annual record
Bring the report, reviewer sign-off and merchant certificate into one evidence-led workflow.
A CLEAR WORKFLOWThe essentials.
The essentials.
The details that matter.
Your workflow
- Review supported storefront journeys and preserve observations.
- Assign remediation and document retests.
- Prepare yearly audit records and merchant certificate display.
Setup considerations
- Use human review for findings that depend on context.
- Confirm the checkout access and journeys included in your review.
- Prepare the merchant certificate after audit review and sign-off.
Rule 4(15) requires a yearly self-audit and prominently displayed certificate from 1 January 2027. The underlying dark-pattern prohibitions already apply; the amendment does not specify every audit method or certificate detail.
Regulatory basis: G.S.R. 789(E), 9 September 2026 and the official government explanation. Effective 1 January 2027. Sources checked 10 October 2026.
BEFORE YOU CONNECTGood questions
Good questions
to ask first.
Understand the records, permissions and review steps behind the workflow.
Does a successful scan certify my store?
No. A scan can record observations and flag potential issues. Context-sensitive findings need human review, and a merchant’s certificate should follow a substantive audit and sign-off.
Is this government certification?
The certificate is the merchant’s own statement following its yearly self-audit. Prepare it from the reviewed findings, remediation and sign-off; it is distinct from government accreditation.
Can the app inspect every checkout journey?
Scope the review to the journeys and access available for your store. Combine automated observations with manual checks for restricted or context-sensitive steps, and record the coverage of the audit.
Where can I read the official requirements?
The guides below link directly to the official Gazette notification, the government’s explanation and relevant NCH materials. Each guide separates the requirement from implementation details.
A LITTLE MORE CONTEXT
All guides →Read before you decide.
Dark Pattern Audit, with clarity.
Bring the right records and next steps together.